David Rotfleisch on Sam Darnold’s Super Bowl & the American “Jock Tax”: How State Taxes Affect NFL Players

The “jock tax” is widely regarded as one of the more intricate and strategically important aspects of U.S. state income taxation, particularly for NFL, NBA, and MLB players, as well as other highly compensated professional athletes whose earnings are apportioned across multiple jurisdictions.

Although professional athletes earn significant salaries, their exposure to state income taxes in numerous states can materially reduce their net income. The “jock tax” refers to the state income tax imposed on nonresident athletes for compensation attributable to services performed within a particular state. For NFL players and similarly situated professional athletes, this regime can create tax filing obligations in multiple states over the course of a single season.

During the 2026 NFL season, quarterback Sam Darnold of the Seattle Seahawks led his team to a 29–13 victory over the New England Patriots in Super Bowl LX. While championship success reflects elite athletic performance, it also underscores the reality that top-tier players remain subject to complex, multi-state income allocation and compliance requirements throughout the season.

An Overview of the ‘Jock Tax’ in U.S. State Income Tax Law

The jock tax is not a distinct federal tax. Instead, it reflects the application of standard state income tax rules to nonresident professional athletes.

States that impose personal income tax generally follow two foundational principles:

• Residents are taxed on their worldwide income.
• Nonresidents are taxed only on income sourced to that particular state.

For professional athletes, most taxing states rely on a “duty-day” allocation formula to determine the portion of income attributable to in-state activities. Under this approach:

• The numerator consists of duty days spent performing services within the taxing state.
• The denominator represents total duty days for the entire season.

The resulting fraction is then applied to the athlete’s total compensation to calculate the amount of income subject to that state’s tax.

For NFL players, total duty days typically range from approximately 160 to 180 per season, depending on training camp, the regular season, playoff participation, and potential Super Bowl appearances. Given the scale of NFL compensation, even a limited number of duty days in a high-tax jurisdiction can generate a substantial state tax liability when annual earnings reach eight figures.

California’s ‘Jock Tax’: A Case Study in High State Taxation

California applies one of the highest top marginal state income tax rates in the United States—currently 13.3% for high-income individuals. For elite NFL players with annual compensation in the tens of millions, even a small number of duty days in California can generate substantial state tax exposure.

Using Sam Darnold as a hypothetical example:

• Estimated total football compensation: approximately $33 million
• Assumed California duty days: five regular-season days plus ten Super Bowl–related days
• Total assumed duty days for the season: 170

If 15 of 170 total duty days are attributed to California, roughly 8.8% of total compensation would be allocated as California-source income. Applied to $33 million, this results in approximately $2.9 million of income subject to California tax.

At a 13.3% marginal rate, the resulting California state income tax liability could approach $385,000—exclusive of any additional playoff or Super Bowl bonuses.

Several technical points are important:

• Super Bowl bonuses earned in California are generally treated as California-source income.
• Media obligations and team preparation days are typically included in the duty-day count.
• Even where no additional base salary is paid for postseason participation, the duty-day formula may increase the percentage of income allocated to California.

This framework illustrates how California’s jock tax can significantly affect an NFL player’s net, after-tax earnings.

Greater Out-of-State Tax Exposure for NFL Players in No-Income-Tax Jurisdictions

NFL players who live in states without personal income tax—such as Washington, Texas, Florida, or Nevada—face distinct multi-state tax challenges.

While most states allow a credit for taxes paid to another state, the rules have key limitations:

• The credit cannot exceed the amount of tax owed to the player’s home state.
• If the home state imposes no income tax, no credit is available.

For example, a quarterback domiciled in Washington cannot offset California jock tax payments with Washington income tax, since Washington does not levy personal income tax. Consequently, California state tax represents a direct out-of-pocket cost. This dynamic is a critical factor in analyzing multi-state taxation for professional athletes.

Federal Tax Impact: Understanding the SALT Deduction Cap

At the federal level, state and local income taxes (SALT) can be deducted only if the taxpayer itemizes deductions, and the deduction is currently around $40,000 (indexed slightly upward each year), subject to income-based phaseouts and sunset rules.

For high-earning professional athletes, state income tax liabilities can easily reach several hundred thousand dollars.

Do Super Bowl Appearances Trigger Unfavorable Tax Outcomes?

Some commentators note that, in theory, an athlete could face a marginal tax rate above 100% on certain portions of allocated income. While this is largely hypothetical, distortions can occur because:

• Base salaries often assume postseason participation.
• Duty-day calculations assign income to states hosting playoff games, even if no extra salary is earned.
• Super Bowl bonuses are taxed by the state where the game takes place.

The combination of state allocation rules, bonus payments, and federal SALT limits can lead to surprising tax outcomes in high-rate states like California.

The Multi-State Tax Compliance Challenges Facing Professional Athletes

The jock tax is not limited to high-profile quarterbacks. It also impacts:

• Backup players
• Coaches and support staff
• Team personnel who travel with the franchise

All of these individuals may need to file multiple nonresident state income tax returns each year. For NFL players and other professional athletes, this creates a complex and potentially costly multi-state tax compliance burden.

Jock Tax Planning Tips for NFL Players and High-Income Athletes

Effective tax planning for professional athletes demands close coordination with experienced advisors and US tax lawyers well-versed in multi-state income tax allocation rules. Key planning considerations often include:

• Assessing domicile status before committing to long-term contracts
• Reviewing the sourcing rules for signing bonuses
• Evaluating the allocation of endorsement and ancillary income
• Tracking duty-day calculations in high-tax jurisdictions
• Aligning federal and state tax strategies to address SALT limitations

Without proactive planning, athletes risk unexpected state income tax obligations, along with potential penalties and interest.

Summary: Understanding the True Impact of the Jock Tax

The jock tax illustrates how state income tax rules can meaningfully affect the net earnings of NFL players and other professional athletes. While achievements like a Super Bowl win can boost an athlete’s brand and future earning potential, high-tax states such as California can substantially reduce short-term after-tax income.

For athletes earning across multiple states, careful state tax planning is critical. Navigating duty-day allocation formulas, state tax credits, domicile considerations, and federal SALT limitations creates a complex multi-state tax landscape that requires the guidance of top tax lawyers to manage exposure and optimize outcomes.

Tax Pro Tips

Athletes and their advisors should carefully track duty days in every taxing jurisdiction and review state income tax allocation rules before signing contracts. It is important to analyze home-state tax credit limitations, particularly for those domiciled in states without an income tax, and to account for the federal SALT cap when modeling after-tax income. Engaging experienced and knowledgeable US tax lawyers is essential for effective multi-state income tax planning.

Frequently Asked Questions (FAQs)

What is the jock tax, and who does it affect?

The jock tax applies state income tax rules to nonresident professional athletes, taxing income earned while performing services in a particular state.

Do all U.S. states collect jock tax?

No. Only states that levy a personal income tax require athletes to pay jock tax. States without an income tax do not impose it.

How do states determine which portion of an NFL player’s income is taxable?

Most states use a duty-day formula, allocating income based on the ratio of days spent performing services in the state to total duty days during the season.

Can living in a no-income-tax state avoid jock tax?

No. Even if an athlete’s home state has no income tax, other states can tax income earned within their borders, and there may be no home-state credit to offset the liability.

Does the federal government tax athletes’ in-state earnings like a jock tax?

No. The federal government does not have a separate jock tax, though federal income tax still applies to total income, and the SALT cap limits the deduction for state income taxes.

DISCLAIMER: This article is intended for general informational purposes only and reflects the law as of the date of posting. It has not been updated and may no longer be current. The content does not constitute legal advice and should not be relied upon as such. Each tax situation is unique and may differ from the examples discussed. You should consult a qualified US tax lawyer for advice tailored to your circumstances.